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Permanent establishment issues paper


This paper focusses on the central role played by PE in Australian international tax law, including:

  • the impact for Australian businesses operating offshore through a PE, including the ability of foreign countries to tax the PE operations, the ability to claim foreign tax credits in Australia for foreign taxes as well as recent changes to the Australian tax treatment of foreign branch income and the quarantining of foreign source deductions
  • what is required for an overseas entity to have a taxable Australian PE under Australian domestic law and as a result of various tax treaties entered into with other countries
  • if a PE exists, what does it mean for the overseas entity (ie registering for income tax, lodging income tax returns etc), non-resident contractors etc.
  • the interaction between Australian domestic tax law and tax treaties, including a detailed discussion of recent case law and the varying implications depending upon the country of residence of the overseas entity.

Author profile

Mathew Chamberlain CTA
Mathew is a Partner at Ernst and Young and leads the International Tax group for Perth. He is a legal practitioner with over 22 years' experience in international tax focusing on the large multinational and corporate environments across Australia, the US, Europe, Asia-Pacific and Africa. Mathew specialises in international tax reform and foreign investment inbound and outbound from Australia. He is a frequent presenter with The Tax Institute and has spoken at both the National and State Conventions on international tax. He is also the WA representative on the Institutes International Tax subcommittee. In addition, Mathew is a seasoned lecturer in tax law at the University of Western Australia and Curtin University, at both postgraduate and undergraduate level. - Current at 08 October 2015
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